Adblock Bristol complaint to the Advertising Standards Authority
Re: Greenwashing Qatar Airways advert
Date: 12th July 2021
To whom it may concern,
We are writing to lodge a formal complaint about a misleading pitchside advertisement by Qatar Airways shown in the UEFA Euro semi-finals on Wednesday 7th July 2021 in Wembley Stadium.
The advertisement, displaying the text “Qatar Airways – Fly Greener” against a green banner, was shown on pitchside advertising boards at regular intervals throughout the >90 minute-long game. The high-profile semi-final between England and Denmark was televised meaning the advert will have reached millions of viewers in the UK and worldwide.
The advert (pictured) misrepresents Qatar Airways’ environmental credentials and misleads consumers who may be influenced to purchase flights under a false impression that this airline provides a sustainable option for air travel.
In this complaint we set out the ways in which this greenwashing advertisement is in breach of Environmental Claim principles 11.1 and 11.3 of the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing:
11.1 The basis of environmental claims must be clear. Unqualified claims could mislead if they omit significant information.
11.3 Absolute claims must be supported by a high level of substantiation. Comparative claims such as "greener" or "friendlier" can be justified, for example, if the advertised product provides a total environmental benefit over that of the marketer's previous product or competitor products and the basis of the comparison is clear.
The advertisement did not display any additional text (see image). As a result, the basis of the environmental claim implied by the use of green visual imagery and sustainability-focused text is not clear, nor is the basis of the comparison implied by the word ‘greener’ (in breach of principles 11.1 and 11.3). This leaves the advert open to misinterpretation by consumers.
The advert in question misleads by stating an environmental claim while simultaneously omitting significant information regarding Qatar Airways’ contribution to global greenhouse gas emissions (in breach of principle 11.1). It uses comparative rather than absolute language in an attempt to avoid censorship; however, the comparison is in breach of principle 11.3 since the airline is not ‘greener’ than competitors, nor has it lowered its own total emissions relative to previous years. The following section aims to supply this information in order to fully reveal the greenwashing nature of the advert.
Qatar Airways in 2021 is not green, nor “greener” than in previous years, nor “greener” than competitors
According to its Annual Report, the Qatar Airways fleet in 2020 consisted of 205 passenger aircrafts, 28 cargo aircraft, 25 executive jets and more planes on order including “five new long-range Boeing 777 freighters to support the further expansion of the Group’s flourishing cargo operations”. The airline is the largest air freight carrier in the world, carrying almost 1.5 million tonnes of cargo in 2019-20, a 2.8% year-on-year increase (Qatar Airways 2020). In 2018-19, prior to the Covid-19 pandemic, the airline carried 29 million passengers to destinations across the world: “Qatar Airways flies to more than 160 destinations spanning six continents. As well as serving more than 29 million passengers, the airline added 11 new destinations to its network in 2018-19” (Qatar Airways 2019). The company plans to expand its fleet, international network and airport to reach a capacity of more than 60 million passengers per year by 2022 (Qatar Airways 2020), which will cause its total direct and indirect greenhouse gas emissions to rise.
Although Qatar Airways does not publicly disclose its Scope 1 or 2 emissions, it can be assumed that the airline’s direct production of greenhouse gases, including CO2, NOx and particle emissions, are already significant. As a useful comparison, similarly-sized airline Korean Air, which in 2019 owned a total of 169 aircraft, flew to 113 cities in 43 countries worldwide, carried 27.35 million passengers and 1.46 million tons of cargo, disclosed emissions of 13.29 million tons CO2e in 2019 (Korean Air 2019).
Qatar Airways currently reports no substantial commitment to reduce its greenhouse gas emissions. It has not gone beyond minimal improvements in its aircraft efficiency and buildings emissions. In 2020 the airline implemented an IATA voluntary offset scheme for passengers which accounts for a minimal proportion of the airline’s assumed total direct emissions (Qatar Airways 2019, 2020, 2021a).
Offset scheme:
Passengers can voluntarily contribute to an offset scheme at the point of booking. According to Qatar Airways’ environmental sustainability webpages, contributions are invested in developing India’s renewable energy capacity via the Fatanpur Wind Farm project which “displaces over 210,000 tonnes of carbon emissions from the Indian Electricity Grid each year” (Qatar Airways 2021a).
Offset schemes are widely met with criticism by experts in light of the urgent requirement to drastically lower global carbon emissions and, further, to implement technologies to remove carbon by the atmosphere as early as 2035 (Lee 2018). Even without the scientific futility of carbon offsetting it is possible to use a conservative example to demonstrate the weakness of Qatar Airways’ offset scheme in comparison to its assumed total direct emissions (which are also predicted to rise). Finnair, the airline determined to be ‘cleanest’ of 20 airlines included in a seven-year study conducted by Warwick Business School (WBS 2016) reported total direct emissions of 3,566,409 million tonnes of CO2 in their 2019 Sustainability Report (Finnair 2019). This amount, reported by a far smaller airline with a fleet of 83 aircraft in 2020 (Finnair 2020), dwarfs the 210,000 tonnes of carbon emissions claimed to be removed from the Indian electricity grid annually via the Fatanpur Wind Farm project that Qatar Airways’ offset scheme finances. The offset programme is clearly also limited by its voluntary nature and the fact that it does not apply to cargo operations.
Qatar Airways is clearly not ‘green’, nor is it ‘greener’ than other airlines who are implementing far more rigorous carbon reduction and offsetting programmes alongside transparent environmental reporting (e.g. Finnair (Finnair 2020)). Its ambitious expansion programme means that its total greenhouse gas emissions will continue to rise and therefore the marketer is also comparatively no ‘greener’ now than in years previous, despite a small scheme to ‘offset’ emissions, a concept that is scientifically questionable in itself given the need not just to avoid further emissions but to remove carbon dioxide from the atmosphere to prevent catastrophic global heating (Lee 2018).
Overall, both the premise and the comparison stated in the advert are false and omit significant information, misleading consumers in breach of principles 11.1 and 11.3.
The role of the ASA
The ASA has upheld claims based on greenwashing by airlines in the past when companies have failed to substantiate their environmental claims. In the context of an urgent need to reduce global greenhouse gas emissions, and the role of the aviation industry as a high polluter, it is insupportable that any airline, let alone one with such a low commitment to sustainability, should be allowed to display advertisements touting their environmental credentials.
Consumers are increasingly looking for ways to minimise their carbon footprint as individuals’ awareness and concern regarding the devastating impacts of climate breakdown grows. The ASA has a crucial role to play in ensuring companies do not mislead people into thinking they are making sustainable choices.
In 2021, using wording and imagery to market an airline as ‘green’ or ‘greener’ is inherently misleading and should be prohibited by advertisement regulatory bodies. Any advertising that perpetuates air travel, the projected increase of which is recognised as incompatible with efforts to limit global heating to <1.5-2oC above pre-industrial levels (Lee 2018), is increasingly insupportable. This highlights a need for greater responsiveness and improved guidance around greenwashing by the ASA as a minimum responsibility.
Summary
Overall, we are concerned that this advertisement breaches CAP Code under Section 11, Environmental Claims. It misleads consumers who may purchase flights under the false impression that their air travel is ‘green’ or environmentally sustainable, or comparatively more so than competitors or the marketer’s previous products, which is not the case.
We argue that this marketing by Qatar Airlines should be openly criticised by the ASA. The advert and similar greenwashing, whether by this airline or any others, should be prevented from appearing at any future sporting or other events and from any broadcast or non-broadcast appearance. The ASA should additionally act proactively to prevent this type of greenwashing given the urgent need to support consumers to act in line with a transition to a low carbon future.
Yours sincerely,
Veronica Wignall, submitted on behalf of Adblock Bristol
About Adblock Bristol
Formed in 2017, Adblock Bristol is a volunteer group who are concerned about the impacts of corporate advertising on our health, wellbeing, environment, climate, communities and the local economy. We lobby for policy change at a local levels, showcase alternatives, organise locally to stop new advertising sites and produce resources to raise awareness about the impacts of commercial advertising. We are part of the national Adfree Cities network.
References
Finnair (2019) Sustainability Report. Available at < https://company.finnair.com/resource/blob/1994132/c493686a5af678b81ed6dbcd48eed150/finnair- sustainability-report-2019-data.pdf>
Finnair (2020) Annual Report. Available at
Qatar Airways (2020) Annual Report. Available at
Qatar Airways (2021a) Environmental Sustainability. Webpage. Available at < https://www.qatarairways.com/en-gb/about-qatar-airways/environmental-awareness.html>
Lee, David (2018) International aviation and the Paris Agreement temperature goals. Department for Transport. Available at
Korean Air (2019) Sustainability Report. Available at
Warwick Business School (2016) Finnair found to be cleanest airline in new study. Press release. Available at